mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014309.json

{
  "document_metadata": {
    "page_number": "5",
    "document_number": "765",
    "date": "08/10/22",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 5 of 95 2743 LCI1MAX1 testimony was that she recruited Carolyn, and she didn't testify, and I don't think -- this is not the theory that the government's been proceeding on on these counts. These counts relate to the four accusers that testified. I think for the jury to infer then that there's enticement with respect to Virginia Roberts, when there's no evidence in the record of Ms. Maxwell or anybody enticing her, there's just testimony that she enticed Carolyn, if anything, that's not an appropriate theory for the jury to base their conviction on foreign commerce, if she's the one who traveled. MR. ROHRBACH: If I may, your Honor. I think for counts -- THE COURT: We're talking 18 U.S.C. 1591, correct? MR. ROHRBACH: Yes. The government does not -- if the Court and defense prefer to remove \"foreign commerce\" from One through Four, Virginia Roberts's conduct doesn't show that. While that's a legally proper instruction to leave \"foreign commerce,\" it's at least available to the jury as to Counts Five and Six because of 18 U.S.C. 1591). THE COURT: But the text of 18 U.S.C. 1591 doesn't include \"in foreign commerce,\" does it? MR. ROHRBACH: Yes. It says, \"Whoever knowingly, in or affecting interstate or foreign commerce, recruits, entices, harbors,\" etc. Oh, I see. It appears that -- SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014309",
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      "content": "testimony was that she recruited Carolyn, and she didn't testify, and I don't think -- this is not the theory that the government's been proceeding on on these counts. These counts relate to the four accusers that testified. I think for the jury to infer then that there's enticement with respect to Virginia Roberts, when there's no evidence in the record of Ms. Maxwell or anybody enticing her, there's just testimony that she enticed Carolyn, if anything, that's not an appropriate theory for the jury to base their conviction on foreign commerce, if she's the one who traveled. MR. ROHRBACH: If I may, your Honor. I think for counts -- THE COURT: We're talking 18 U.S.C. 1591, correct? MR. ROHRBACH: Yes. The government does not -- if the Court and defense prefer to remove \"foreign commerce\" from One through Four, Virginia Roberts's conduct doesn't show that. While that's a legally proper instruction to leave \"foreign commerce,\" it's at least available to the jury as to Counts Five and Six because of 18 U.S.C. 1591). THE COURT: But the text of 18 U.S.C. 1591 doesn't include \"in foreign commerce,\" does it? MR. ROHRBACH: Yes. It says, \"Whoever knowingly, in or affecting interstate or foreign commerce, recruits, entices, harbors,\" etc. Oh, I see. It appears that --",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014309",
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  "entities": {
    "people": [
      "Carolyn",
      "Virginia Roberts",
      "Ms. Maxwell",
      "MR. ROHRBACH"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "765",
      "18 U.S.C. 1591",
      "DOJ-OGR-00014309"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}